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Review of national registration scheme must heed doctor concerns

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It’s now four years since the National Registration and Accreditation Scheme for health practitioners was introduced and, as planned, it is undergoing a post-implementation review. 

I’ve been chairing an AMA working group preparing our submissions to the review. In the last five months we have been actively engaging with the review and the independent reviewer, Kim Snowball. 

To date, the working group have made three submissions on behalf of AMA members:

·         an initial letter setting out the AMA’s broad position on the scheme and overarching principles for medical practitioner regulation;

·         a seven-page submission expanding on the key issues the AMA believes the review should consider; and

·         a response to the consultation paper released in August.

We’ve also participated in stakeholder consultation forums that have been held in each State.

One of our key concerns is about the timely and proper triaging of notifications and complaints. 

Under the scheme, notifications are used to bring concerns about an individual practitioner’s conduct or performance to the attention of the regulator.  The regulator investigates to determine if there is a risk of harm to the public, and takes appropriate disciplinary action.

By contrast, health consumer complaints seek resolution for the consumer. Unless there is a broader risk to the public, consumer complaints received by Australian Health Practitioners Regulation Agency (AHPRA) are forwarded to State and Territory health complaint entities (HCEs) for resolution. 

The review consultation paper proposes a greater standing for the health consumer in the investigation of a notification, and a dispute resolution process for individuals.

The AMA strongly opposes this.

AMA members report that the notification process is arduous and lengthy – 31 per cent of investigations are still open after nine months – and often complicated by poor communication from AHPRA.

Such lengthy processes can be very distressing for the doctors involved, and the long time taken no doubt undermines the confidence of consumers in the effectiveness of the scheme.

With respect to notifications, the AMA has called for:

  • improved triaging of complaints and notifications, to keep complaints which divert resources from notifications outside of the scheme; and
  • a scheme that is more responsive to medical practitioners, and accountable to the medical profession.

So, it was with disappointment that I read the AHPRA Action Plan which was released on 24 September.

It makes reference to a joint Victorian Health Issues Centre and AHPRA report, Setting Things Right, which focuses on the consumer experience with the scheme.

The AHPRA Action Plan sets out the actions AHPRA intends to take to improve the experience of health consumers.

The review consultation paper covers most of the issues raised in the Setting Things Right report.

The AHPRA Action Plan therefore not only pre-empts the review’s outcomes, it takes no account of the views of health practitioners regulated by the scheme.

Our concerns with the Action Plan are two-fold.

AHPRA wants even more information to be shared with people who have made a notification, and its focus is on improving the experience for consumers, when in fact efforts need to be directed to improving the investigation process – that is, the practitioner experience.

Medical practitioners and consumers, equally, want a regulatory scheme that is timely, fair, transparent and effective. 


I have written to AHPRA and the Medical Board clearly stating our concerns with the pre-emptive release of the AHPRA Action Plan, and the fact that peak practitioner groups were not consulted about the measures in the Action Plan. 

The AMA is ready to work with AHPRA and the Medical Board to identify ways the scheme can be made more efficient and effective to afford due process for practitioners, and to ensure the National Register provides appropriate information to help consumers make an informed decision when choosing a health practitioner.

I firmly believe this is the only way to maintain the confidence of all stakeholders in the national scheme.

The AMA’s submissions to the review can be viewed at: submission-ama-submissions-review-national-registration-and-accreditation-scheme